Which country's law decides who inherits my Israeli estate?

Most people assume that because the apartment sits in Tel Aviv, Israeli inheritance rules must decide who gets it. That is not how Israel handles the question. Israeli law looks first at where the deceased lived, not where the property sits, and for a non-resident that single distinction can change who inherits.

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Detailed Explanation

The governing provision is Section 137 of the Succession Law 1965. It says succession is governed by the law of the deceased's moshav (domicile, or centre of life) at the time of death. Israel follows a unitary model here: in principle one legal system decides the fate of the whole estate, movable and immovable, rather than splitting the estate by asset type the way some common-law countries do. So a person who died domiciled in New Jersey, owning an apartment in Haifa, will usually have New Jersey succession law applied to that apartment by the Israeli court.

That general rule has a real exception for real estate. Section 138 provides that where the foreign law itself refers questions about immovable property back to the law of the place where the property is located, Israeli law applies to the Israeli property. Because many legal systems apply lex situs to land, this "renvoi" often pulls Israeli succession law back into the picture for the apartment itself, even while the deceased's domiciliary law governs the bank accounts and securities. Working out which law lands where is a genuinely technical exercise, and it is decided case by case.

There is also a public-policy floor. An Israeli court will not apply a foreign succession rule that offends Israeli public order, and it retains the protective provisions of the Succession Law for a surviving spouse and dependants. If your home country imposes forced heirship, that regime does not automatically bind the Israeli assets either, a point covered in our answer on whether Israel has forced heirship rules.

For a non-resident, the practical consequence is this. Whichever law governs distribution, the Israeli assets do not move until the Inheritance Registrar (Rasham HaYerushot) issues an Israeli succession order (tzav yerusha) or, where there is a will, a will execution order. Foreign heirs file that application from abroad through an Israeli lawyer under an apostilled power of attorney. The death certificate, the will, and proof of the heirs' identities all have to be apostilled in the issuing country and translated into Hebrew before the Registrar will act. If the estate raises a genuine conflict-of-laws question, the Registrar can transfer the file to the Family Court, which may require a formal opinion on the foreign law.

In Practice: Under Section 137 of the Succession Law 1965, the Inheritance Registrar applies the law of the deceased's last domicile to the estate, subject to the Section 138 exception for Israeli immovable property. Where a foreign-law opinion is needed, an Israeli expert opinion typically costs NIS 3,000 to 8,000, and if the file moves to the Family Court the timeline stretches well beyond the 6 to 14 weeks an uncontested Registrar application takes.

Key Considerations

• Israel applies the deceased's last domicile law to the estate as a whole, not the location of each asset.
• Israeli real estate can still be pulled under Israeli law through the Section 138 renvoi rule.
• Foreign forced-heirship regimes do not automatically bind Israeli assets.
• An Israeli succession order is required to transfer the Israeli property regardless of which law governs distribution.
• A real conflict-of-laws dispute usually moves the file from the Registrar to the Family Court.

When to Consult a Lawyer

This question typically requires professional legal advice when:

• Your home country applies forced heirship or community-property rules that differ from your Israeli will.
• The estate mixes Israeli real estate with Israeli bank or brokerage accounts, so different laws may apply to different assets.
• An heir abroad disputes which country's law should decide the distribution.

A qualified Israeli attorney should map the conflict-of-laws position before any succession application is filed, because the governing law shapes who is even entitled to apply.

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Speak With an Israeli Attorney

We assess which country's law governs a non-resident's Israeli estate, obtain the succession order from the Inheritance Registrar, and coordinate with your home-country probate so the two systems align.

Contact us for a confidential initial consultation.